Lending Service Provider

List of Lending Service Provider (LSP) engaged by Datson Exports Limited to avail their services of Digital Lending is as follows:

Credify Technologies Private Limited (CTPL).

Details of activities for which Credify Technologies Private Limited has been engaged by Datson Exports Limited:

Datson Exports Limited has entered into an agreement to avail the services of Digital Lending of CTPL through its Digital Lending App (DLA) called ‘Creditt’,'Creditt+' for the disbursement of short-term loans of small amounts to salaried individuals who apply directly for the loan through the DLA.

Datson Exports Limited has not entered into any agreement with any other Company/ Agency for availing any other services.

The shares of the Company are listed at Calcutta Stock Exchange.

Datson Exports Limited is a RBI registred NBFC (Non - Deposit Taking). The Fallowing are the Director Details of the Company

Director Details : Mrs Pragati Mundhra , Mr. Raghav Das Mundhra , Mr. Ranji Saha , Mr. Ravi Prakash Agarwal

11/1C/2 East Topsia Road, Kolkata – 700046.

Email: info@datson.net

Email: customer.support@creditt.in

Company: Datson Exports Limited

Loan Service Provider: Credify Technologies Pvt Ltd

DLA : Android ,iOS

Mobile: 089767 65488

Financials

Shareholding Pattern

Investors Information

Contact Us

11/1C/2 East Topsia Road, Kolkata – 700046.

Email: info@datson.net

Investors Correspondence May Be Addressed To :

Director & Compliance Officer : Mrs Pragati Mundhra

Director Details : Mrs Pragati Mundhra , Mr. Raghav Das Mundhra , Mr. Ranji Saha , Mr. Ravi Prakash Agarwal

Datson Exports Limited

11/1C/2 East Topsia Road, Kolkata – 700046.

Tel :- +91-33-22851012

Mobile :- 089767 65488

Fax :- +91-33-22528013

Email: info@datson.net

Email: customer.support@creditt.in

Credit Policy

SCORING TO EVALUATE RISK PROFILE

For customers, the system divides risk assessment in 3 main parts.

Score from employment and user background

Employment details we consider for scoring	Employment Sector, Occupation Details, Company Name, Company Address, Company Contact Number, Employment Type, Employed Since When, Monthly Salary.
Basic user details we consider for scoring	Residential Status, Purpose of the Loan, Location..

Score from financial data & bank statement analysis

Parameters we consider for scoring from financial data &bank statement and/or net banking data

Opening Balance, Closing Balance, Minimum Average Balance, Maximum Average Balance, Average Balance, Inflow Count, Total Inflow Amount, Outflow Count, Total Outflow Amount, Cash Withdrawal Count, Total Cash Withdrawal Amount, Cheque Received Count, Total Cheque Received Amount, Cheque Issue Count, Total Cheque Issue Amount, Number of Salaries, Total Salary Amount, Average Salary Amount, Actual vs. User Entered Salary, Income vs. Expenditure, Cash Deposit Count, Total Cash Deposit Amount, Bounced Count, Total Bounced Amount, Loan/EMI Payment Count, Total Loan/EMI Payment Amount, Penalty Count, Total Penalty Amount, Bank Charges Count, Total Bank Charges Amount, Total Investment.

Score from ML risk assessment algorithm

Parameters ML algorithm considers to generate score and predict to approve or decline the loan

Applied Loan Amount, Loan Interest, Validated Salary, App Platform, Contact Count, Age, Loan App Count, Bounced Cheque Amount, Total Amount Inflow, Cash Deposit Amount, Total Amount Outflow, Withdrawal Amount, Loan Payment Amount, Bank Charges Amount, Penalty Charges Amount, Closing Balance, Opening Balance, Investment Amount, Total Salary.

Based on all three scoring systems we generate a ‘Credit Risk Score’ of a user which we show them before accepting the loan ( loan amount, loan tenure, rate of interest, processing fees)

INTEREST RATE POLICY

For new customers, the standard interest rate calculation is considered where the rate of interest is decided based on customer’s TDSR score at the time of applying the loan. TDSR is derived from the financial data customer shares with us.

TDSR = Total Debt Service Ratio= {( Debit Avg. / Avg. Duration ) – ( Investments / Avg. Duration)} / {(Credit Avg. / Avg. Duration) + Opening Balance} X 100

TDRS	Interest Rate Per Day
<90< /td>	0.30 %
91 to 95	0.40 %
96 to 100	0.50 %
>100	0.60 %

For existing customers, the interest rate is calculated based on their past repayments. For that we consider on time repayment percentage as the main parameter. Below is the calculation:

On Time Repayment Percentage =(No. On time repayments X 100) /No.Total Repayments

On Time Repayment %	Interest Rate Per Day
>95%	0.30 %
90% to 94.99%	0.40 %
85% to 89.99%	0.50 %
<85%< /td>	0.60 %

DELINQUENT ACCOUNTS POLICY

This policy establishes the procedures to be followed should an account have an open receivables balance more than 7 days past due. In congruence with the Credit bureau reporting (TU CIBIL), at that time, it’s labeled as “severely delinquent.” The collection team alerts the sales and lending team to the outstanding balance, and the legal team will send a letter marked Final Notice to the customer. The account is placed on credit hold; barring future loan applications from being processed or disbursed. The collection and recovery team will work with the customer to resolve the past due payment issues. If the outstanding balance is not resolved with payment, the revenue is canceled, and the account now must be treated in adherence with the company’s Bad Debt Policy.

BAD DEBT/COLLECTIONS POLICY

When a severely delinquent account (90+ days past due) is not resolved with a good faith effort of payment, the expense may be written off to bad debt. Our company’s deﬁnition of bad debt is an uncollectible balance owed from a customer experiencing ﬁnancial hardship such as bankruptcy. Non- paying accounts can be written off to bad debt only after the customer has gone out of business, has ﬁled for bankruptcy, or has been placed for collections and payment has not been secured after six months (180 days). If every attempt at collection fails, otherwise outstanding balances are turned over to our company’s collections agency (a third party) if approved by the Collections Head.

Credit Policy

Grievance Redressal Mechanism

Datson Exports Limited (DEL) is a Non-Banking Finance Company (NBFC) registered under Section 45IA of the Reserve Bank of India Act, 1934. DEL ensures that the highest possible standards of ethics and moral conduct are followed by its staff from the top management to each employee at every level in the organisation. DEL ensures that all the compliance requirements as prescribed by the RBI vide its notifications, circulars and the rules made thereunder are complied with to the best of the Company’s ability and understanding. As per the broad guidelines issued by RBI, DEL has a proper Grievance Redressal Mechanism in place to receive and address the disputes raised by the customers and ensure that they are resolved in a timely manner; expeditiously and fairly.

DEL maintains and follows a transparent and fair procedure while offering a suitable grievance mechanism to its customers, thereby ensuring that the trust of the customers is maintained.

DEL has the following mechanism in place:

Datson Exports Limited has appointed Mr. Raghav Mundhra as the Nodal Officer (NO) at their Head/Registered/Regional/Zonal Offices and informed all the Offices of the Ombudsman about the same.
The NO so appointed is responsible for representing the company and furnishing information to the Ombudsman in respect of complaints filed against the NBFC.
Wherever more than one zone/region of a NBFC is falling within the jurisdiction of an Ombudsman, one of the NOs shall be designated as the ‘Principal Nodal Officer’ (PNO) for such zones or regions.
The appointed NO/PNO is responsible, inter alia, for representing the covered NBFC before the Ombudsman and the Appellate Authority under the Scheme.
The PNO/NO appointed at the Head Office of the NBFC is responsible for coordinating and liaising with the Customer Education and Protection Department (CEPD), RBI, Central Office.
The Company has also appointed the Grievance Redressal Officer (GRO) identified by the respective NBFCs in terms of extant guidelines on Grievance Redressal Mechanism, applicable to them, provided that the officer concerned is sufficiently senior in the organisation. Where there is more than one Nodal Officer for a zone, the PNO shall be responsible for representing the company and furnishing information to the Ombudsman in respect of complaints filed against the NBFC.

Therefore, with a view to strengthening the Grievances Redressal System and enhancing its effectiveness, the Company ensures that they take necessary steps as outlined above and as laid down by the Honorable RBI.

ARBITRATION & JURISDICTION
In case any dispute arises between DEL and customer, and the parties are unable to reach a solution within a period of thirty (30) days, then upon written notice by any one party to the other, the dispute, claim, Question or difference shall be resolved by a sole arbitrator appointed with the mutual consent of both parties as per the Arbitration & Conciliation Act, 1996 and such proceedings shall be conducted at Ahmedabad, in accordance with their Arbitration Rules.

These Terms and Conditions shall be governed by and construed in accordance with the laws of India. The parties hereto submit to the exclusive jurisdiction of the courts of Ahmedabad at Gujarat in India.
In case of any violations or grievances with relation to these Terms, the customers can write and, or reach out to the Company at legal@datson.net

INTEREST RATE POLICY

Datson Exports Limited is a Non-Banking Finance Company (NBFC) engaged in the business of disbursing short term small amount loans to individual borrowers through a Digital Lending Platform i.e., a mobile app 'Creditt','Creditt+' which are registered and highly remarkable (Owned and managed by Credify Technologies Pvt. Ltd). 'Creditt' and 'Creditt+' are an innovative and revolutionary online money lending app in the fintech industry. To make it more clear, 'Creditt' and 'Creditt+' are an instant online loan application that provides small and micro finance loans.

The rate of interest would be between 0.30% – 0.60% on the loans and advances per day to our individual borrowers.

The interest rate is charged on the daily basis. The same is calculated on the basis of a customer’s profile. Customer’s profile is highly risky and they fall under under-served group of the community/society. Their profile is at a minimum level as far as the credit history is concerned and some of them are not covered under formal channel of credit scoring i.e. Credit Bureaus, Banks, Financial Institutions.

The business model has been designed and developed to accommodate real-time changes with version tracking. In order to secure a personal loan, the following qualifying conditions should be met:

Applicants must be an Indian resident
Applicant must be over 21 years of age and under 55 years of age
Applicants would be employed with a minimum wage of Rs. 20,000

The Company serves people who don’t have access to bank finance and some of them are not covered under formal channel of credit scoring i.e. Credit Bureaus, Banks, Financial Institutions.

The Company provides short tenure payday loan; loan amount ranging from Rs. 10000 to Rs. 35000. The minimum tenure of the loan is 1 day and maximum of 45 days. The Company is a 100% digital and paperless platform featuring real-time credit/risk assessment algorithm. The company has successfully set up infrastructure to collect money owed by the NBFC and which is why we follow the procedures diligently. The company has in house technology team to maintain, enhance and to add and remove features in the app i.e. CREDITT INSTANT LOAN APP and CREDITT+ INSTANT LOANS & MORE. The company has successfully set up the following departments namely – Collection, both on field and also through the digital medium which is through tele collection (managed by registered and recognized call centre), technology team – to maintain and enhance the feature of the loan platform to better serve the customers which will lead us to pass on the benefit to the end users to reduce interest rate. The company also has also high customer acquisition costs on account of the marketing and operations department. The other cost which accounts for 25% of the expense of the company is the delinquency cost –default given the high risk profile of the customer segment we will serve. The company borrows from its lenders at 15% to 30% per annum. the said funds will be used for lending, working capital requirement (customer sourcing, technology, marketing, collection, operations and delinquency/ default expenses). The same will have considerable impact on company’s P&L Account. Having said that, the company is dedicated to serve the customer diligently by putting the infrastructure and resources in place.

FAIR PRACTICES CODE

This has reference to RBI Circular No. 2012-13/416/DNBS. CC. PD No. 320 /03.10.01/2012-13 dated 18th February, 2013, wherein the Reserve Bank of India (RBI) has revised the guidelines on Fair Practices Code for NBFCs to implement the same.

The Fair Practices Code, as mentioned herein below, is in conformity with these Guidelines on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circular. This sets minimum Fair Practice standards for the Company to follow when dealing with customers. It provides information to customers and explains how the Company is expected to deal with them on a day to day basis.

This policy applies to all customers including those with any complaints / enquiries as posted on social / any other media and we encourage all customers to reach out to the below platforms as required.

Objective of the Code

The code has been developed with an objective of:

Ensuring fair practices while dealing with customers Greater transparency enabling customers in having a better understand the product and taking informed decisions Building customer confidence in the company

Applications for Loans and their processing

The Company offers various financial products including Term loan, Loan against property, Lease rental discounting, Loan for purchase of commercial property purchase among others. The below clause however will only apply with respect to retail loan viz. home loan, personal loan etc., wherein the borrower is an individual and who would requires assistance as compared to mid- large corporate clients who are well versed and equipped with financial market business.

The 'Application Form / appropriate documents' of Datson Exports Limited for each of these products offered by the Company is different depending upon the requirement of each product and will include all information that is required to be submitted by the Borrower. Necessary information will be provided by Sampati Securities Limited to facilitate the Borrower in making a meaningful comparison with similar terms and conditions offered by other Non-Banking Finance Companies (NBFCs) and taking an informed decision based on the aforesaid comparison.

The 'Application Form/ appropriate documents' of Datson Exports Limited may also indicate the list of documents required to be submitted by the Borrowers along with the Application form.

Datson Exports Limited has a mechanism of giving an acknowledgement for receipt of Application form to its Borrower for availing loans. Datson Exports Limited would inform the Borrower about its decision within reasonable period of time from the date of receipt of all the required information in full.

Loan appraisal and terms/ conditions

Datson Exports Limited shall convey in writing to the Borrower by way of a sanction letter or otherwise, the amount of limit sanctioned along with all the terms and conditions including annualized rate of discount/ interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on Datson Exports Limited record.Any clause relating to penal interest charged for late repayment will be specified in bold in the Loan Agreement. Datson Exports Limited at the time of sanction / disbursements of loans will furnish a copy of loan agreement to the borrower.

Disbursement of loans including changes in terms and conditions

Through its published website or as appropriate if specific to a customer, Datson Exports Limited will give Notice to its Borrower(s), of any change in the terms and conditions of the sanction. Datson Exports Limited will also ensure that changes in discount/ interest rates andcharges are effected only prospectively.

Decision to recall/ accelerate payment or performance under the Agreement will be in consonance with the respective loan Agreement.

Datson Exports Limited will release all securities of its Borrower only on repayment of alldues by such Borrower, or only on realization of the outstanding amount of the Borrower's availed limit, subject to any legitimate right or lien for any other claim which Datson Exports Limited may have against its Borrower. If such right of set off is to be exercised, the Borrower will be given notice about the same with full particulars about the remaining claims and conditions under which Datson Exports Limited will be entitled to retain the securities till the relevant claim is settled or paid by the Borrower. Due No-objection certificate will be issued to the customer on fulfilment of said terms within 15 workings days of completion of formalities.

General

• Datson Exports Limited will refrain from interference in the affairs of its Borrower except for the purposes provided in the terms and conditions of the respective loan agreement (unless new information, not earlier disclosed by the Borrower, which may come to the notice of Datson Exports Limited) In case of receipt of request from the Borrower for transfer of Borrowal account, the consent or otherwise i.e. objection of Datson Exports Limited, if any, is generally conveyed to such Borrower within 21 days from the date of receipt of the Borrower's request. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.
• In the matter of recovery of outstanding dues of its Borrower, Datson Exports Limiteddoes not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans/dues, etc. Training will be imparted to ensure that staff is adequately trained to deal with customers in an appropriate manner.

Grievance Redressal Mechanism

In the present competitive scenario, excellent customer service is an important tool for sustained business growth. Customer complaints are part of the business life in any corporate entity. At Datson Exports Limited, customer service and satisfaction are our prime focus. We believethat providing prompt and efficient service is essential not only to attract new customers, but also to retain existing ones. Datson Exports Limited has come up with a lot of initiatives that are oriented towards providing a better customer experience and an efficient complaints Redressal mechanism with a view to providing enhanced experience to our customers.

In order to make Datson Exports Limited Redressal mechanism more meaningful and effective, a structured system has been built. This system would ensure that the redressal sought is just and fair and is within the given frame- work of rules and regulation.

Machinery to handle customer complaints/ grievances

Customers who wish to provide feedback or send in their complaint may use the following channels between 9:30 am and 6:00 pm, from Monday to Friday (except on national holidays).

Call our Complaint Redressal Officer On 08097452970

Email us at : customer.support@creditt.in

Write to us at the below mentioned address:

Datson Exports Limited

11/1C/2 East Topsia Road, Kolkata – 700046.

In case the complaint is not resolved within the given time or if he/she is not satisfied with the solution provided by Datson Exports Limited, the customer can approach the Compliance Officer. The contact of the Compliance Officer is as follows:

Tel. No.: 08097452970

Email Id: legal@datson.net

We assure a response to letters / emails received through this channel within 5 working days.

If the complaint/dispute is not redressed within a period of one month, the customer may appeal to Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision of RBI under whose jurisdiction the Registered Office of the Datson Exports Limited falls. The details of DNBS is as given below:

Dy. General Manager, Department of Non-Banking Supervision

Reserve Bank of India,

Kolkata Regional Office

Netaji Subhas Road,

Kolkata – 700 001, West Bangal

Mandatory display requirements

Datson Exports Limited has the following in Registered Office:

Appropriate arrangement for receiving complaints and suggestions.
Display of the name, address and contact number of the Complaint Redressal Officer The process of the complaints redressal will ensure closure of all complaints to the customers'satisfaction.

They will ensure that the complaint is escalated to the appropriate levels in case it is not possible to resolve at his/her level. Whilst the ultimate endeavor is to ensure we reach a situation where our customers don't have to complain to senior management to get an effective redressal, we have put in a robust mechanism to handle these complaints, review them from a point of view of understanding reasons for the complaint and for the escalation and working on prevention of recurrence thereof.

Time frame

To register complaints, the customers may use any of the channels mentioned above on Internal Machinery to handle the customer complaints). If the complaint has been received in writing, Datson Exports Limited will endeavor to send an acknowledgement / response within a week. Once the matter is examined, Datson Exports Limited endeavours to either send a finalresponse to the customer or an intimation seeking more time within one month upon receipt of complaint. Complaints that are received at our end will be seen in the right perspective and would be analyzed from all possible angles.

The communication of Datson Exports Limited stand on any issue will be provided to the customers. Complaints that require some time for examination of issues involved will be acknowledged promptly.

The aforesaid policy will be reviewed periodically /revised as and when there are any new changes incorporated by Datson Exports Limited in handling complaints / grievances of the customer which includes introduction of new grievance channels, if any.

Regulation of Excessive Interest charged

The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges.

The Company has adopted an interest rate model taking into account cost of funds, margin and risk premium for determining rate of interest to be charged for loans and advances.The rate of interest to be charged depends much upon the gradation of the risk of borrower viz. the financial strength, business, regulatory environment affecting the business, competition, past history of the borrower etc.

The rate of interest will be annualised so that the borrower is aware of the exact rates that would be charged to the account.

POLICY: Ensuring the monitoring over Digital lending platform

Datson Exports Limited is an RBI registered NBFC. That the company has partnered with Credify Technologies Private Limited. (Creditt – Instant Loan app , Creditt+ Instant Loans & More) as its technology/ app partner. The said arrangement is entered into as per the RBI outsourcing guidelines for NBFC. The company disburses loan amount to the borrowers and the customers at the fixed interest basis and on the daily basis. For the same we do share details to our clients/customers. That the interest rate is being charged by NBFC to the borrowers as per the RBI guidelines.

Our company does adhere to the Fair Practice Code. As per the guidelines laid down RBI, we do abide and follow the following necessary instructions:

Our Digital lending platform engaged as agents discloses upfront to the customer, the name of the NBFC on whose behalf they are interacting
Immediately after sanction but before execution of the loan agreement, the company issues as well as provides the sanction letter to the borrower on the letter head of the NBFC.
A copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement is furnished to all borrowers at the time of sanction/ disbursement of loans.
Effective oversight and monitoring is ensured over the digital lending platform engaged by the NBFCs.
Adequate efforts are made towards creation of awareness about the grievance redressed mechanism.

Our Lending cycle and process and why we collect data

Lending app discovery and registration
Loan application processing
User verification
Loan disbursement
Loan repayment

Loan Application Processing

The user fills the application and thereby provides a host of information about himself. Based on these details, the app pulls his credit score, historical banking information, mobile recharge history, etc. from the phone. Each app uses its own proprietary algorithm to score the user based on his creditworthiness and chooses to underwrite the loan.

User Verification

Based on the underwriting, the app displays the loan options that the user is eligible for. The user chooses the appropriate loan option. The user then verifies his identity and e-signs the loan.

Loan Disbursement

The loan amount is then credited into the user’s account, many times to wallets and sometimes to bank accounts. Many of the apps are found to manage cash disbursement through deemed brokers.

Loan Repayment

Based on the repayment plan, the user pays back the interest and principal amount in the agreed number of instalments. In case of delay, the LSPs in the business of collection/ recovery step in.

One of the first steps in the digital lending lifecycle is requesting access to various apps and services on the user’s phone. This has been a key concern for consumers and regulators alike. For example, e- KYC requires access to a borrower’s camera to verify their identity. Location data is required to prevent fraud and confirm the location of the borrower.

Our board approved outsourcing policy ensures the due diligence to monitor and review the operations and policies periodically.

Our regulatory body ensures customer data privacy and security.

Our company ensures fair treatment of borrowers, the regulated entity and their agents shall not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude the privacy of the debtors' family members, referees and friends, making threatening and anonymous calls or making false and misleading representations.

Our recovery agents adhere to code of fair practice.

POLICY FRAMEWORK ON ‘KNOW YOUR CUSTOMER’ (KYC) AND ANTI-MONEY LAUNDERING MEASURES

Datson Exports Limited (SSL) is a Non-Banking Finance Company (NBFC) bearing registration number 05.00683 registered under Section 45IA of the Reserve Bank of India Act, 1934. The Company has entered into an outsourcing agreement with “Credify Technology Private Limited” (CTPL) to avail their services of Digital Lending through their online Digital Lending Platform called the 'Creditt' and 'Creditt+' apps, to lend loans of small amount to e- borrowers. The KYC and anti-money laundering measures adopted practically by CTPL are in line with the Policy mentioned herein. The Company ensures that a policy framework on ‘Know Your Customer” (KYC Policy) – Anti Money Laundering Guidelines is in place, as per the directions issued by the Reserve Bank of India through its circular DNBS(PD).CC No. 34/10.01/2003-04 dated January 6, 2004

Datson Exports Limited ensures that:

The Company follows the customer identification procedure for opening of accounts and monitoring transactions of a suspicious nature for the purpose of reporting it to appropriate authority.
The Company ensures that the information collected from the customer for the purpose of opening of account is kept confidential and the Company does not divulge any details thereof for cross selling or any other purposes.
The Company ensures that information sought from the customer is relevant to the perceived risk, is not intrusive, and is in conformity with the guidelines issued in this regard. Any other information from the customer is sought separately with his /her consent and after opening the account.

This Policy is framed by incorporating the following four key elements:

Customer Acceptance Policy;
Customer Identification Procedures;
Monitoring of Transactions;
Risk management

Customer Acceptance Policy ( CAP )

The Company has a Customer Acceptance Policy, laying down explicit criteria for acceptance of customers. The following guidelines on the aspects of customer relationship are in place:

No account is opened in anonymous or fictitious/ benami name(s);
Parameters of risk perception are clearly defined in terms of the nature of business activity, location of customer and his clients, mode of payments, volume of turnover, social and financial status etc. customers requiring very high level of monitoring, e.g. Politically Exposed Persons may, if considered necessary, be categorised higher;
Documentation requirements and other information is collected in respect of different categories of customers depending on perceived risk and keeping in mind the requirements of PML Act, 2002 and guidelines issued by Reserve Bank from time to time;
The Company does not open an account or close an existing account where the Company is unable to apply appropriate customer due diligence measures i.e. the Company is unable to verify the identity and /or obtain documents required as per the risk categorisation due to non co-operation of the customer or non-reliability of the data/information furnished to the Company. There is a suitable built in safeguards to avoid harassment of the customer.
Circumstances, in which a customer is permitted to act on behalf of another person/entity, is clearly spelt out in conformity with the established law and practice of banking as there could be occasions when an account is operated by a mandate holder or where an account may be opened by an intermediary in the fiduciary capacity
Necessary checks before opening a new account so as to ensure that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations etc.

The Adoption of Customer Acceptance Policy and its implementation is not restrictive and does not result in denial of banking services to general public, especially to those, who are financially or socially disadvantaged

Customer Identification Procedure ( CIP )

the Company follows a CIP so as to obtain information and identify the customers. The following guidelines are adhered to:

The Company obtains sufficient information necessary to establish, to their satisfaction, the identity of each new customer, whether regular or occasional, and the purpose of the intended nature of banking relationship. Such risk based approach is necessary to avoid disproportionate cost to banks and a burdensome regime for the customers.
For customers that are natural persons, the Company obtains sufficient identification data to verify the identity of the customer, his address/location, and also his recent photograph.

Monitoring of Transactions

The Company monitors the activity of the customers so that they have the means of identifying transactions that fall outside the regular pattern of activity. The extent of monitoring depends on the risk sensitivity of the account.
The Company pays special attention to all complex, unusually large transactions and all unusual patterns which have no apparent economic or visible lawful purpose.
Transactions that involve large amounts of cash inconsistent with the normal and expected activity of the customer are brought to the attention of the bank.
The Company ensures that a record of transactions in the accounts is preserved and maintained as required in terms of section 12 of the PML Act, 2002 and the transactions of suspicious nature and/ or any other type of transaction notified under section 12 of the PML Act, 2002, are reported to the appropriate law enforcement authority.

Risk Management

The Company ensures that an effective KYC program is put in place by establishing appropriate procedures and ensuring their effective implementation. It covers proper management oversight, systems and controls, segregation of duties, training and other related matters.

The Company’s internal audit and compliance function are in place to evaluate and ensure adherence to the KYC policies and procedures.

The Company has an ongoing employee training program so that the members of the staff are adequately trained in KYC procedures. Training requirements have different focuses for frontline staff, compliance staff and staff dealing with new customers.

Customer Education

Implementation of KYC procedures requires the Company to demand certain information from customers which may be of personal nature or which has hitherto never been called for. This can sometimes lead to a lot of questioning by the customer as to the motive and purpose of collecting such information. The customer is educated about the objectives of the KYC program.